EL26-69-000 · 2026-08-03 · Central Hudson Gas & Electric CorporationConsolidated Edison Company of New York, Inc.New York State Electric & Gas Corporation ,Niagara Mohawk Power Corporation d/b/a National Grid ,Orange and Rockland Utilities, Inc. ,Rochester Gas and Electric Corporation ,

Request for Abeyance of the New York Transmission Owners and Request for Expedited Commission Action and Shortened Comment Period

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
New York Independent System Operator, Inc. 
 ) 
 
 
 
 
 
 
 
 ) 
Central Hudson Gas & Electric Corporation 
 ) 
Consolidated Edison Company of New York, Inc. ) 
Docket No. EL26-69-000 
LS Power Grid New York Corporation I  
 ) 
 
New York State Electric & Gas Corporation  
 ) 
New York Transco LLC 
 
 
 
 ) 
NextEra Energy Transmission New York, Inc. 
 ) 
Niagara Mohawk Power Corp.  
 
 
 ) 
Orange and Rockland Utilities, Inc. 
 
 ) 
Rochester Gas and Electric Corporation    
 ) 
 
REQUEST FOR ABEYANCE OF THE NEW YORK TRANSMISSION OWNERS AND 
REQUEST FOR EXPEDITED COMMISSION ACTION AND SHORTENED 
COMMENT PERIOD 
 
 
Central Hudson Gas & Electric Corporation, Consolidated Edison Company of New York, 
Inc., New York State Electric & Gas Corporation, Niagara Mohawk Power Corporation d/b/a 
National Grid, Orange and Rockland Utilities, Inc., and Rochester Gas and Electric Corporation 
(collectively referred to herein as the “New York Transmission Owners” or “NYTOs”)1 
individually and collectively, pursuant to the Federal Energy Regulatory Commission’s 
(“Commission”) Order Instituting Proceeding Under section 206 of the Federal Power Act 
(“FPA”)2 issued June 18, 2026,3 hereby respectfully request that the Commission hold in abeyance 
all aspects of the above-captioned proceeding described below, including the 60-day deadline to 
 
1  
New York Power Authority (“NYPA”) and Long Island Power Authority (“LIPA”) are members of the New 
York Independent System Operator, Inc. (“NYISO”).  In this case, the Commission did not name NYPA and 
LIPA as parties in the Show Cause Order and therefore they are not filing parties to this abeyance request.  
Nevertheless, as intervenors in this case, NYPA and LIPA generally support this abeyance request to allow 
for coordination among the NYISO and NYTOs on shared responsibilities and vetting with stakeholders on 
future FPA section 205 filings.  
2  
16 U.S.C. § 824e. 
3  
N.Y. Indep. Sys. Operator, Inc., 195 FERC ¶ 61,216 (2026) (“Show Cause Order”).

2 
respond to the Show Cause Order, for a full period of 90 days, commencing as of August 17, 2026.  
This request is submitted within the 45-day window prescribed by the Show Cause Order and is 
supported by the substantive description of the anticipated FPA section 2054 filing(s) set forth 
herein.5   
The NYTOs understand that the NYISO is also submitting an abeyance request under 
separate cover in this docket.  The NYTOs support abeyance for the NYISO as well and appreciate 
the progress that the NYISO has made to date.  The NYISO developed an extensive initial proposal 
that was presented to stakeholders at the July 23 Transmission Planning Advisory 
Committee/Electric System Planning Working Group meeting.6  While much work remains to be 
done, and while the NYISO presentation is under review by the NYTOs, the presentation is a 
promising start.  The NYTOs observe that the NYISO has successfully worked cooperatively with 
stakeholders in developing Order No. 20237 and Order No. 19208 compliance filings, and the 
NYTOs are confident that the NYISO will be able to do so here.  While the NYTOs possess 
unilateral filing rights for certain issues (as discussed below), if granted an abeyance by the 
Commission, the NYTOs commit to coordinate closely with the NYISO and stakeholders and may 
 
4  
16 U.S.C. § 824d. 
5  
As explained below, the NYTOs have not yet determined the procedural vehicle for their forthcoming FPA 
section 205 filing, which may take the form of a companion, NYTO-specific filing, or, if the NYTOs and 
NYISO mutually agree, a joint NYISO and NYTOs filing.  In either case, the NYTOs commit to coordinate 
closely with the NYISO and stakeholders. 
6  
NYISO, Large Load FERC Show Cause Order (July 23, 2026) (“NYISO Show Cause Order Presentation”), 
https://www.nyiso.com/documents/20142/58620525/04_FERC%20Large%20Load%20Show%20Cause%2
0Order%20-%20ESPWG.pdf/3b66b965-05ad-51e6-a4c5-c9846eeada4c. 
7  
Improvements to Generator Interconnection Procs. & Agreements, Order No. 2023, 184 FERC ¶ 61,054, 
order on reh’g, 185 FERC ¶ 61,063 (2023), order reh’g & clarification, Order No. 2023-A, 186 FERC ¶ 
61,199 (2024), petition for review denied sub nom. Advanced Energy United, et al. v. FERC, No. 23-1282 
(D.C. Cir. July 31, 2026). 
8  
Bldg. for the Future Through Elec. Reg’l Transmission Planning and Cost Allocation, Order No. 1920, 187 
FERC ¶ 61,068, order on reh’g & clarification, 189 FERC ¶ 61,126 (2024), order on reh’g & clarification, 
191 FERC ¶ 61,026 (2025).

3 
submit separate a NYTO-only FPA section 205 filing or, should the NYTOs and NYISO mutually 
agree, join a single FPA section 205 filing with the NYISO, as appropriate. 
I. 
BACKGROUND 
A. 
The Show Cause Order 
On June 18, 2026, the Commission issued the Show Cause Order, instituting a proceeding 
under FPA section 206 based on the Commission’s preliminary finding that the NYISO’s Open 
Access Transmission Tariff (“OATT” or “Tariff”)9 appears to be unjust, unreasonable, or unduly 
discriminatory or preferential.10  The Commission issued the Show Cause Order as part of a suite 
of six coordinated orders directed to each of the RTO/ISO regions subject to the Commission’s 
jurisdiction. 
The Show Cause Order includes preliminary findings that the NYISO’s Tariff appears 
unjust and unreasonable in five principal respects: 
1.  Transmission Service Study Process for Large Loads.  The Commission 
preliminarily found that the NYISO’s Tariff lacks sufficiently clear and consistent provisions 
addressing: (a) a definition of large load as a distinct category of load; (b) a mandatory application 
process, readiness requirements, and study procedures for Eligible Customers seeking 
transmission service on behalf of large loads; (c) study timelines of no more than 60-90 calendar 
days; (d) ongoing operational requirements – including telemetry, data reporting, remote 
disconnect capability, ramp rate and ride-through requirements, and protection systems – for 
transmission customers serving large loads; (e) evaluation of alternative transmission technologies 
 
9  
Capitalized terms not otherwise defined herein have the meanings set forth in the NYISO OATT or Market 
Administration and Control Area Services Tariff, as applicable.   
10  
Show Cause Order at P 3.

4 
as potential solutions in lieu of or in addition to traditional Network Upgrades; and (f) pro forma 
provisions in transmission service agreements to memorialize operational requirements.11 
2.  Cost Transparency and Cost Recovery.  The Commission preliminarily found that 
the NYISO Tariff lacks: (a) robust, centralized, publicly accessible data on its website regarding 
the Network Upgrades and associated costs needed to provide transmission service to Eligible 
Customers on behalf of large loads; and (b) a pro forma cost recovery agreement between the 
NYISO, the relevant Transmission Owner, and the Eligible Customer taking transmission service 
on behalf of a large load, with a minimum financial contribution and credit support requirement 
sufficient to mitigate the risk of cost shifting among transmission customers.12 
3.  Co-Location Arrangements and Behind-the-Meter Generation.  The Commission 
preliminarily found that the NYISO’s Tariff lacks: (a) a definition of co-located load; (b) 
sufficiently clear and consistent provisions governing the rates, terms, and conditions of service 
applicable to interconnection customers serving co-located load, including required ancillary 
service charges (regulation and black start service on a gross demand basis); and (c) provisions 
addressing netting of behind-the-meter generation from gross load for purposes of calculating 
applicable Transmission Service Charges in a manner consistent with the cost causation 
principle.13 
4.  New Transmission Services for Eligible Load and Flexible Large Loads.  The 
Commission preliminarily found that the NYISO’s Tariff lacks transmission services that reflect 
 
11  
Show Cause Order at PP 56-71. 
12  
Id. PP 77-91. 
13  
Id. PP 101-110.  See, e.g., Tenaska Clear Creek Wind, LLC v. FERC, 108 F.4th 858, 868-69 (D.C. Cir. 2024) 
(“[T]he cost causation principle requires that ‘all approved rates reflect to some degree the costs actually 
caused by the customer who must pay them.’”) (quoting S.C. Pub. Serv. Auth. v. FERC, 762 F.3d 41, 88 
(D.C. Cir. 2014)).

5 
the operational capabilities of Eligible Customers taking transmission service on behalf of Eligible 
Load (co-located load and load with behind-the-meter generation) and flexible large loads that are 
willing and able to limit their energy withdrawals from the transmission system under certain 
conditions, specifically: (a) an interim non-firm network transmission service (“Interim NITS”) 
available while Network Upgrades are being constructed; and (b) permanent firm and non-firm 
contract demand transmission services.14 
5.  Generator Interconnection for Electrically Proximate Large Load and Co-Located 
Load.  The Commission preliminarily found that the NYISO’s Tariff lacks generator 
interconnection study procedures and generator interconnection services tailored to reflect an 
interconnection customer’s commitment to limit a generating facility’s output to match the hourly 
forecast of an electrically proximate large load or large co-located load, thereby potentially 
reducing the need for Network Upgrades and accelerating the interconnection process.15 
The Show Cause Order directs the NYISO and the named Transmission Owners, within 60 
days of issuance (i.e., by August 17, 2026), to either: (1) show cause as to why the Tariff remains 
just and reasonable and not unduly discriminatory or preferential without provisions addressing 
the foregoing concerns; or (2) explain what Tariff changes would remedy those concerns were the 
Commission to determine that the Tariff is in fact unjust and unreasonable and to establish a 
replacement Tariff.16  The Commission separately directed the NYISO to submit, within 30 days 
of issuance (i.e., by July 18, 2026), an informational report on its plans to ensure adequate 
generation to serve existing and new large loads.17  
 
14  
Id. PP 109, 112-113. 
15  
Id. PP 121-127. 
16  
E.g., id. P 3.  
17 
Id. PP 128-129.

6 
The Show Cause Order also provides the NYISO and/or the Transmission Owners the 
opportunity to seek to hold all or certain aspects of the proceeding in abeyance while they develop 
FPA section 205 filings to address the Commission’s concerns.  Specifically, the Show Cause 
Order states that: 
 The Commission will consider requests for abeyance of up to 90 days; 
 The abeyance period will begin as of the deadline to respond to the Show Cause 
Order (August 17, 2026); 
 Abeyance requests must be submitted within 45 days of the issuance of the Show 
Cause Order (i.e., by August 3, 2026); 
 The Commission will not grant abeyances reflexively, and will look with great 
disfavor toward requests to extend the abeyance period beyond 90 days; and 
 Successful abeyance requests must include both: (1) a robust description of the 
content of a potential future FPA section 205 filing; and (2) a reasoned and specific 
explanation of when such a filing is expected to be made.18 
The NYTOs submit this filing on August 3, 2026, within the 45-day window, and it 
includes a detailed description of the NYTOs’ plans to coordinate with the NYISO and 
stakeholders to address the issues identified in the Show Cause Order. 
B. 
The NYTOs’ Independent Filing Rights Under the NYISO-TO Agreement  
The NYTOs file this request independently from the NYISO, in accordance with the rights 
explicitly reserved in section 3.10(a) of the NYISO-TO Agreement.19  Section 3.10(a) provides, in 
relevant part, that: 
Each Transmission Owner shall have the right at any time 
unilaterally to file pursuant to Section 205 of the Federal Power Act 
to change the ISO OATT, a Service Agreement under the ISO 
OATT, or the ISO Agreement to the extent necessary: (i) to recover 
all of its reasonably incurred costs, plus a reasonable return on 
investment related to services under the ISO OATT and (ii) to 
 
18  
Id. P 42. 
19  
NYISO, Foundation Agreements, Agreement Between New York Independent System Operator and 
Transmission Owners (0.0.0) (“NYISO-TO Agreement”).

7 
accommodate implementation of, and changes to, a Transmission 
Owner’s retail access program.20 
Critically, section 3.10(a) confers upon each Transmission Owner the unilateral right to 
file with the Commission under FPA section 205 – independent of the NYISO’s 
concurrence – to the extent necessary to recover reasonably incurred costs associated with 
services provided under the NYISO OATT and to accommodate changes to the NYTOs’ 
retail access programs.21 
The Show Cause Order expressly recognizes this allocation of rights and 
responsibilities.  Indeed, the Commission acknowledged that “the Transmission Owners 
may be partially responsible for conducting the studies that (1) evaluate whether a large 
load may be interconnected to the transmission system and served by the Eligible Customer 
and (2) determine whether Network Upgrades are necessary to provide transmission 
service.”22  The Commission further explained that it “appreciate[s] that this role may stem 
from how NYISO and the Transmission Owners allocated rights and responsibilities in the 
governing documents establishing NYISO” and “does not seek to alter that allocation of 
rights and responsibilities.”23 
Several matters addressed in the Show Cause Order directly implicate the NYTOs’ 
ability to recover their reasonably incurred costs through Commission-jurisdictional 
transmission rates.  As the Commission itself acknowledges, the costs of Network 
 
20  
Id. § 3.10(a). 
21  
See id. § 3.03 (providing that “[n]otwithstanding any other provision in this Agreement except for the 
provisions of Section 3.10,” proposed OATT revisions are subject to certain stakeholder and NYISO 
governance procedures (including review by the NYISO Board of Directors) before being filed at FERC) 
(emphasis added). 
22  
Show Cause Order at P 58. 
23  
Id.

8 
Upgrades needed to provide transmission service to Eligible Customers on behalf of large 
loads are inputs to jurisdictional transmission rates and are recovered through each 
Transmission Owner’s Annual Transmission Revenue Requirement.24  Accordingly, the 
NYTOs’ independent filing rights under section 3.10(a) of the NYISO-TO Agreement are 
squarely implicated with respect to key issues identified below. 
Section 3.10(a) also provides an independent, second basis for the NYTOs’ 
unilateral FPA section 205 filing rights that is equally applicable to certain key issues 
identified below: the right to file “to accommodate implementation of, and changes to, a 
Transmission Owner’s retail access program.”  The Show Cause Order’s directives directly 
implicate the NYTOs’ retail access obligations.  Specifically, any cost transparency 
requirements, cost recovery agreements, and study process reforms at issue would directly 
affect how large loads – including retail transmission service customers that qualify as 
Eligible Customers under the transmission provider and/or Transmission Owner tariffs – 
are interconnected and served under each NYTO’s retail access program.  Thus, the Tariff 
reforms at issue here will necessarily affect each NYTO’s retail access obligations, 
engaging the retail access prong of section 3.10(a) as an additional, independent basis for 
the NYTOs’ filing authority.   
II. 
REQUEST FOR ABEYANCE  
The NYTOs respectfully submit this request for a full 90-day abeyance of the above-
captioned show cause proceeding.  The NYTOs recognize the urgency of the Commission’s 
concerns regarding the integration of large and co-located loads onto the New York transmission 
 
24  
Id. PP 20, 85.

9 
system and are committed to working with the NYISO to develop comprehensive, regionally-
tailored solutions. 
As detailed below, the NYTOs have already begun the processes, which are directly 
responsive to the Commission’s concerns.  Granting a full 90-day abeyance will allow those 
processes to advance to the point at which the NYTOs can propose – either in a potential joint FPA 
section 205 filing with the NYISO or in a companion FPA section 205, NYTO-only filing – Tariff 
revisions addressing the full scope of the Commission’s preliminary findings that are within the 
purview of the NYTOs.  Indeed, the Commission expressly recognized that the Transmission 
Owners “may elect to address some or all of the issues discussed in this order by proposing 
revisions to the Tariff pursuant to their applicable FPA section 205 filing rights” and stated that it 
“strongly encourage[s]” the NYISO and/or NYTOs to submit FPA section 205 filings.25  
Proceeding through an FPA section 205 filing that is developed in coordination with NYISO, the 
New York Public Service Commission (“NYPSC”), and other stakeholders rather than through 
FPA section 206 litigation will produce more targeted, operationally sound proposals that are 
better calibrated to NYISO’s unique market structure, resource adequacy construct, and existing 
Tariff framework. 
Consistent with section 3.10(a) and the Commission’s own recognition of the NYTOs’ 
independent role described above, the instant proceeding falls squarely within the scope of the 
NYTOs’ unilateral filing rights, which extend to matters that directly affect their ability to recover 
reasonably incurred costs through Commission-jurisdictional transmission rates and to 
modifications to their retail access programs.  The Show Cause Order raises important questions 
about the adequacy of the NYISO’s Tariff provisions relating to: (1) the study process for 
 
25  
Id. P 41.

10 
transmission service requests on behalf of large loads, the results of which directly determine what 
Network Upgrades are required and the associated costs that flow into each NYTO’s transmission 
rates, including potentially a pro forma interconnection agreement that memorializes the results of 
that study process; (2) cost recovery agreements that would require Eligible Customers to bear the 
risk of costs incurred to provide transmission service, including Network Upgrade costs; (3) 
revenue crediting mechanisms to ensure that payments made pursuant to such cost recovery 
agreements are appropriately reflected in, and do not result in double recovery through, each 
NYTO’s transmission rates applicable to other FERC-jurisdictional customers; (4) transmission 
service charges and new transmission service products – including firm and non-firm withdrawal 
service and contract demand-based service – needed to reflect the operational characteristics of 
large loads and co-located loads; (5) cost transparency mechanisms that will directly affect the 
public visibility of each NYTO’s transmission-related costs; and (6) operating requirements 
applicable to non-firm transmission withdrawal service and paired or behind-the-meter generation 
supplies.  Each of these issues is inextricably linked to the NYTOs’ ability to recover their 
reasonably incurred costs under the Tariff and to changes to the manner in which the NYTOs 
provide retail transmission services – the precise subject matter of the independent filing rights 
preserved under section 3.10(a) of the NYISO-TO Agreement. 
A full 90-day abeyance is warranted here.  The issues identified in the Show Cause Order 
are substantial in scope and technical complexity, encompassing potential new large load study 
processes, cost recovery and transparency mechanisms, co-location Tariff provisions, new 
transmission service products, and new generator interconnection services.  Creating thorough and 
technically valid Tariff proposals to address the Commission’s concerns, including those areas 
within the NYTOs’ scope of reserved rights, requires sufficient time for active collaboration

11 
between the NYTOs, the NYISO, and other parties listed in the Show Cause Order, and also for 
adequate consultation with subject matter experts.  The 90-day abeyance period is the minimum 
time necessary to responsibly advance this work and to vet with stakeholders, coordinate with the 
NYISO, and deliver proposals of the quality and comprehensiveness the Commission has invited.  
The NYTOs are committed to using the abeyance period efficiently and anticipate making an FPA 
section 205 filing (either in a potential joint filing with the NYISO or in a companion NYTO-only 
standalone filing) to address the issues raised in the Show Cause Order that fall within the NYTOs’ 
purview. 
III. 
DESCRIPTION OF ANTICIPATED FPA SECTION 205 FILING  
Consistent with the Show Cause Order’s requirement that a successful abeyance request 
include a robust description of the content of any anticipated FPA section 205 filing, the NYTOs 
provide the following description of the Tariff revisions they anticipate proposing in coordination 
with the NYISO and stakeholders.  Specifically, NYTOs have identified the following areas that 
fall within the purview of their independent, unilateral FPA section 205 filing rights pursuant to 
section 3.10(a) of the NYISO-TO Agreement: (1) cost allocation and recovery; (2) mechanisms to 
ensure that payments made by Eligible Customers pursuant to cost recovery agreements or Tariff 
provisions are appropriately credited toward each NYTO’s transmission revenue requirement to 
the extent such costs are included in such revenue requirements consistent with the Commission’s 
cost-of-service regulations; (3) rate design issues concerning new transmission services reflecting 
the operational characteristics of large loads, co-located loads, and flexible large loads willing and 
able to limit their use of the transmission system;26 (4) aspects of the load interconnection study 
 
26  
The preservation of the tax exempt status for certain NYTOs as well as for local furnishing bonds will need 
to be preserved as well.

12 
process for which the NYTOs will be responsible (including the Facilities Study); and (5) certain 
operational requirements for Eligible Customers taking service on behalf of large loads, along with 
any necessary agreements and Tariff changes to implement the foregoing.27  
The NYTOs note that, under their unilateral filing rights found in section 3.10(a) of the 
NYISO-TO Agreement, they are not required to seek approval of their proposed FPA section 205 
filing through the NYISO stakeholder process.  However, the NYTOs commit to sharing their 
proposals with the NYISO and stakeholders during the abeyance period to seek feedback, and note 
that, as a result, the specific scope and provisions of the anticipated filing described below may be 
further refined and altered.   
The NYISO has indicated that, if the Commission grants an abeyance in this proceeding, 
the NYISO will present elements of an FPA section 205 filing during meetings with the NYTOs 
and stakeholders scheduled to occur as frequently as weekly through November 16, 2026.  The 
NYTOs will be primarily responsible for certain key functions and, as such, will reserve time at 
those meetings to present the proposals for stakeholder feedback.  In parallel, the NYTOs and the 
NYISO will allocate responsibility for drafting Tariff provisions and agreements to revise the 
relevant large load interconnection and cost allocation and recovery procedures as appropriate. 
At this stage, the NYTOs do not know if they will (i) join with the NYISO an FPA section 
205 filing that addresses all issues raised in the Show Cause Order or (ii) submit a companion, 
NYTO-only filing that addresses the issues within the NYTOs’ unilateral FPA section 205 filing 
rights.  In either case, however, the NYTOs will coordinate closely with the NYISO and other 
stakeholders. 
 
27  
This is not intended to be an exclusive list of the items within the NYTOs’ unilateral FPA section 205 filing 
right and does not constitute a waiver of any NYTO filing right.

13 
A. 
Cost Recovery and Transmission Service Charges 
1. 
Network Upgrade Cost Recovery 
The Commission preliminarily found in the Show Cause Order that the NYISO Tariff 
appears unjust and unreasonable because it lacks adequate mechanisms to mitigate the risk of cost 
shifting among transmission customers.  First, the Commission noted the lack of Tariff provisions 
requiring NYISO to post in a single location on the NYISO website certain Network Upgrade and 
cost data and other related information.28  Second, the Commission pointed to the absence of a pro 
forma cost recovery agreement between NYISO, the relevant Transmission Owner, and the 
Eligible Customer taking transmission service on behalf of large loads that helps ensure that 
Eligible Customers bear the risk and are ultimately responsible for costs incurred to provide 
transmission service, including Network Upgrade costs.29  The Commission also contemplated the 
possibility of Transmission Owners entering into cost recovery agreements with large load 
customers themselves rather than the corresponding Eligible Customers.30 
The NYTOs plan to coordinate with NYISO, NYPSC, the New York Department of Public 
Service (“DPS”),31 and other interested stakeholders to develop a process for the Transmission 
Owner to recover from the Eligible Customer or large load customer, as applicable, an allocable 
share of the cost of Transmission Owner Interconnection Facilities and Network Upgrades.   
In a single-state ISO like the NYISO, a state public utility commission is in a good position 
to address cost allocation issues associated with upgrades to accommodate large loads.  Among 
other factors, the NYPSC will be in a good position to balance various benefits provided by 
 
28  
Id. P 77. 
29  
Id. P 83. 
30  
Id. P 88. 
31  
The NYPSC is housed within the DPS. N.Y. Pub. Serv. Law § 4 (McKinney 2024).

14 
upgrades in terms of reliability, public policy, and economic benefits for all loads.  The NYPSC 
and NYISO have a highly coordinated transmission planning process, which integrates the 
NYPSC’s Comprehensive Grid Planning Process and the NYISO’s long-term planning process 
developed pursuant to Order No. 1920.  In addition, each NYTO has bundled retail rates covering 
transmission and distribution revenue requirements established by the NYPSC. 
 The NYPSC is also currently presiding over a proceeding to address cost allocation and 
issues associated with large load interconnections.32  A July 14, 2026 Executive Order issued by 
New York Governor Kathy Hochul similarly directed the DPS to take certain action “to identify 
and resolve issues related to the interconnection of data centers, and other large loads, in order to 
support efficient interconnection of large new customers and the faithful compliance of 
‘beneficiary pays’ principles as related to network upgrade and resource adequacy costs.”33  The 
July 14, 2026 Executive Order and Show Cause Order appear to be driven by similar or shared 
concerns.  The cost allocation framework that the NYTOs ultimately include in a cost recovery 
agreement that they will submit for FERC review in a subsequent FPA section 205 filing will thus 
need to be developed in close coordination with DPS. 
Specifically, the NYTOs will file under FPA section 205 a mechanism by which each 
Connecting Transmission Owner or Affected Transmission Owner, as applicable, will recover an 
allocable share of the cost of Transmission Owner Interconnection Facilities and Network 
Upgrades.  Cost recovery will be obtained from the Eligible Customer taking transmission service 
on behalf of the large load or, where the Transmission Owner or Affected Transmission Owner 
 
32  
NYPSC Case No. 26-E-0045, Proceeding on Motion of the Commission to Address Interconnection Reforms 
for Large Loads, Order Instituting Proceeding and Soliciting Comments (Feb. 12, 2026). 
33  
Exec. Order 62: Establishing a Temporary Moratorium on Data Centers in New York While the State 
Develops Higher Standards for Data Center Development and Benefits Blueprint to Support Localities (July 
14, 2026), https://www.governor.ny.gov/sites/default/files/2026-07/EO_62.pdf.

15 
and the large load customer enter into a cost recovery agreement directly, from the large load 
customer.  The NYTOs intend to incorporate the NYPSC’s cost allocation determinations and to 
file with the Commission a proposed mechanism – likely in the form of a  pro forma agreement 
and/or Tariff provisions  – consistent with the Commission’s jurisdiction.  In some cases, costs 
from upgrades may be shared among more than one Eligible Customer or large load customer in 
a load interconnection cluster.  The NYTOs will also describe the security posting requirements 
as part of the rates, terms, and conditions applicable to large loads to address situations in which a 
large load triggers substantial investments in upgrades.  The NYTOs intend to include these 
requirements in a legally enforceable framework set forth in a pro forma cost recovery agreement 
and/or Tariff provisions applicable to Eligible Customers or large load customers. 
Moreover, the NYTOs will provide for “head room adjustments” so that when a future 
Eligible Customer or large load customer, as appropriate, utilizes head room created by a Network 
Upgrade for which an earlier Eligible Customer or large load customer is paying charges to the 
Connecting Transmission Owner or Affected Transmission Owner, the earlier Eligible Customer’s 
or large load customer’s costs are reduced based on the cost responsibility allocated to the new 
Eligible Customer or large load customer.   
NYISO commenced operations in 1999.  The NYPSC has been regulating all aspects of 
Transmission Owner retail access programs including, in some cases, bundled retail transmission 
and distribution rates since 1996, when the NYPSC issued its landmark Opinion No. 96-12 
directing utilities in New York to file, inter alia, “a schedule for the introduction of retail access” 
to the utilities’ customers.34  The NYPSC has also regulated cost allocation, rate design, and cost 
 
34  
In the Matter of Competitive Opportunities Regarding Electric Service, Case 94-E-0952, et al., Opinion No. 
96-12 at 82 (1996).

16 
recovery associated with upgrade costs for all retail customers, including large retail access 
customers.  The NYTOs intend to work collaboratively with NYPSC to establish transmission 
upgrade cost allocation, which would then be implemented through pro forma agreements and/or 
Tariff provisions to be submitted in the forthcoming FPA section 205 filing.35  In developing this 
mechanism, the NYTOs will consider structural approaches similar to the novel cost recovery 
arrangements the Commission has previously accepted.36  Such arrangements may include a 
minimum financial contribution from the large load customer or Eligible Customer, as applicable, 
toward the Transmission Owner’s transmission revenue requirement, coupled with a credit support 
or other financial security requirement sufficient to protect other transmission customers if the 
large load does not ultimately take the anticipated level of transmission service. 
2. 
Revenue Crediting 
The Commission also preliminarily found in the Show Cause Order that any payments 
made by an Eligible Customer (or by a large load) to a Transmission Owner pursuant to a cost 
recovery agreement should be appropriately credited toward the Transmission Owner’s 
transmission revenue requirements consistent with the Commission’s cost-of-service regulations37 
if the costs allocated to the Eligible Customer were otherwise being recovered in FERC-
jurisdictional rates.  On this issue, the Commission noted that “it appears reasonable for filers of 
formula rates to provide a separate workpaper in the annual informational filing describing how 
 
35  
If the NYTOs propose in the forthcoming FPA section 205 filing – and the Commission accepts – a pro 
forma agreement, any non-conforming iterations of that agreement will be filed with FERC moving forward. 
36  
See, e.g., Show Cause Order at P 75 & n.181 (citing Commonwealth Edison Co., 194 FERC ¶ 61,106 (2026); 
Commonwealth Edison Co., 194 FERC ¶ 61,109 (2026); Commonwealth Edison Co., 194 FERC ¶ 61,110 
(2026); Commonwealth Edison Co., 194 FERC ¶ 61,113 (2026); PECO Energy Co., 193 FERC ¶ 61,148 
(2025); Dayton Power & Light Co., 192 FERC ¶ 61,103 (2025); Dayton Power & Light Co., 189 FERC ¶ 
61,220 (2024)). 
37  
Id. P 91.

17 
any payments made pursuant to a cost recovery agreement are reflected in the transmission owner’s 
transmission formula rate.”38   
In a forthcoming FPA section 205 filing, the NYTOs will provide for periodic NYTO-
specific filings with the Commission describing whether the applicable NYTO has included costs 
of Network Upgrades allocated to one or more Eligible Customers or large load customers, as 
applicable, in the NYTO’s rate base in Commission-jurisdictional rates applicable to other 
transmission customers.  Specifically, if a NYTO has included any such Network Upgrade costs 
in its FERC-jurisdictional rates applicable to other Eligible Customers or large load customers, the 
NYTO will provide for a revenue credit to the extent the NYTO is recovering those Network 
Upgrade costs.  Alternatively, the NYTO may include in a Commission filing with its next update 
in the formula rate applicable to FERC-jurisdictional transmission service a statement that the 
NYTO has not included Network Upgrade costs allocated to specified Eligible Customers or large 
load customers in the NYTO’s rate base for FERC-jurisdictional rates paid by other transmission 
customers or that the NYTO has included only an allocable share of such costs and an explanation 
for the allocation. 
3. 
Transmission Service Charges 
In the Show Cause Order, the Commission preliminarily found that NYISO’s Tariff is 
unjust and unreasonable because it lacks transmission services reflecting Eligible Customers’ 
taking service on behalf of:  (1) co-located load and/or load with behind-the-meter generation and 
(2) flexible large loads that are willing and able to limit energy withdrawals from the transmission 
system under certain conditions.39  Among other things, the Commission directed the NYISO 
 
38  
Id. 
39  
Show Cause Order at PP 101-110, 112-113.

18 
either to (1) explain whether the Tariff remains just and reasonable without an interim non-firm 
network transmission service while Network Upgrades are being constructed (i.e., Interim NITS) 
and without permanent firm and non-firm contract demand transmission services (transmission 
service up to a specified MW quantity, i.e., the contract level, on a firm or non-firm basis) or (2) 
propose Tariff revisions.40 
The NYISO has indicated that, to address the Commission’s concerns, it intends to provide 
“Firm Withdrawal Service” for large loads that do not cause resource adequacy or transmission 
security adverse impacts or have completed all necessary resource adequacy supply and 
transmission security Network Upgrades as needed.41  For other large loads, NYISO will offer 
“Non-Firm Withdrawal Service.”42  NYISO has explained that large loads taking Firm Withdrawal 
Service “will be treated the same as other customers taking firm service, including having the same 
curtailment priority,” while large loads that take Non-Firm Withdrawal Service “will have a lower 
curtailment priority than NYISO’s firm transmission service, including Firm Withdrawal 
Service.”43 
The NYTOs appreciate the NYISO’s efforts thus far and intend to collaborate closely with 
the NYISO to develop the constructs further.  The NYTOs intend to work with the NYISO to 
ensure that the rates reflected in the charges associated with such new transmission services accord 
with the cost causation principle44 but reserve the right to utilize the NYTOs’ independent and 
 
40  
Id. PP 109, 113. 
41  
NYISO Show Cause Order Presentation, supra note 6, at 32. 
42  
Id. 
43  
Id. 
44  
See supra note 13.

19 
unilateral FPA section 205 filing rights under section 3.10(a) of the NYISO-TO Agreement if 
necessary. 
Specifically, the NYISO has indicated it will settle with large loads or Eligible Customers 
taking service on behalf of large loads for certain charges under the NYISO OATT and Market 
Administration and Control Area Services Tariff, including applicable locational-based marginal 
prices at the Point of Withdrawal, which cover the transmission charges for congestion and 
marginal losses, and applicable ancillary service charges.  These charges, however, do not address 
each NYTO’s embedded costs of transmission.  Since the NYISO’s inception in 1999, the NYTOs 
have used a “license plate” rate design.  Each NYTO uses an embedded cost formula rate, the 
Wholesale Transmission Service Charge (“TSC”), for “wheel through” and “export” transactions 
that exit the New York Control Area.45  In addition, as noted above, each NYTO has bundled retail 
rates covering transmission and distribution revenue requirements established by the NYPSC.  
Such NYPSC-established retail rates also include System Benefits Charges to support entry of new 
electric supplies, retention of nuclear resources, and other public policies.  It is essential that rates 
applicable to large loads or Eligible Customers taking service on behalf of large loads reflect 
appropriate allocations of such System Benefits Charges as the NYPSC determines appropriate 
based on its consideration of all retail loads in the State.  
The NYPSC also accounts for Wholesale TSC revenues, Transmission Congestion 
Contract (“TCC”) auction revenues, congestion rents, and grandfathered transmission contract 
revenues that each NYTO receives or pays so that retail customers receive the benefits of 
transmission-related revenues and pay their allocable share of costs.  This balancing of revenues, 
 
45  
See NYISO OATT Attach. H, § 14.1.

20 
demand, and costs is part of the development of the rates applicable to retail customers in New 
York, including large loads.  
Each NYTO also has retail TSCs that are established by the NYPSC, including charges 
applicable to large load customers.  Historically, each NYTO has referenced a state-approved retail 
service classification for such loads as provided for in the Retail Transmission section of the OATT 
(section 5).  The NYTOs plan to continue this practice and will develop tariff provisions for 
submission to the NYPSC and NYISO OATT provisions for submission to FERC to identify how 
rates are established and updated from time to time.  As is the case today, the applicable 
jurisdictional rates will be referenced in section 5 of the OATT and remain subject to FERC 
review.  
The NYTOs will include in a forthcoming FPA section 205 filing any changes in rates 
deemed necessary in order to accommodate Firm Withdrawal Service and Non-Firm Withdrawal 
Service.  The different forms of service may require changes in the billing determinants, billing 
units, demand allocators, and cost allocation mechanisms.  The NYTOs are working on these 
issues and will consult the NYISO, NYPSC, DPS, and other stakeholders in advance of the FPA 
section 205 filing. 
B. 
Large Load Interconnection Procedures and Agreements 
The Commission preliminarily found in the Show Cause Order that the NYISO and/or 
NYTOs should modify the NYISO OATT and/or agreements to address: the scope and timing of 
interconnection studies, including the Facilities Studies; 46 the evaluation of transmission service 
requests for large loads;47 Eligible Customer or large load operational requirements – including 
 
46  
Show Cause Order at PP 65, 69. 
47  
Id. PP 65-66.

21 
dispatch, curtailment, and disconnection provisions that are subject to rights held by both the 
NYISO and the Connecting Transmission Owner and/or Affected Transmission Owner;48 
information requirements, study deposits, and study assumptions and procedures;49 Facilities 
Study procedures;50 and interconnection agreement terms, conditions, and transparency. 
1. 
Interconnection Study Provisions  
The NYTOs are responsible for significant interconnection and transmission service study 
work associated with large loads.  This work must be conducted in close coordination with the 
NYISO because of the bifurcated nature of the study process.  Accordingly, without waiving any 
rights, the NYTOs intend to develop coordinated study processes with the NYISO and anticipate 
a unified set of terms and conditions that will be part of a NYISO or a potential joint NYISO-
NYTO FPA section 205 filing.  
 The Commission acknowledged that the NYTOs bear a distinct and independent role in 
this process.  Specifically, the Commission recognized that “the Transmission Owners may be 
partially responsible for conducting the studies that (1) evaluate whether a large load may be 
interconnected to the transmission system and served by the Eligible Customer and (2) determine 
whether Network Upgrades are necessary to provide transmission service.”51  The Commission 
further stated that it “appreciate[s] that this role may stem from how NYISO and the Transmission 
Owners allocated rights and responsibilities in the governing documents establishing NYISO” and 
expressly confirmed that it “do[es] not seek to alter that allocation of rights and responsibilities.”52  
 
48  
Id. P 70. 
49  
Id. P 46. 
50  
Id. P 90. 
51  
Id. P 58. 
52  
Id.

22 
This acknowledgment is significant as it confirms that the NYTOs’ role in the study process is not 
merely derivative of NYISO’s obligations under the Tariff, but rather reflects an independent 
allocation of responsibilities that the Commission has expressly declined to disturb. 
The NYTOs are committed to working with the NYISO and stakeholders to address the 
Commission’s preliminary guidance.  Consistent with the large load interconnection process 
improvements under development with the NYISO, the NYISO would continue to perform Load 
System Impact Studies (“Load SIS”) with improvements to make results more valuable.  
Following the Load SIS, as proposed by the NYISO, the NYISO and the Connecting Transmission 
Owner would engage in an alternate evaluation process in which NYISO identifies the bulk power 
system violations that must be addressed on a more granular level, and the Connecting 
Transmission Owner identifies the non-bulk system violations and proposed solutions for all of 
those violations in the Facilities Study.   
As part of the Facilities Study, the NYISO would review the proposed solutions for their 
adequacy to resolve the identified bulk power system violations.  This process entails a number of 
important handoffs and integrated coordination between the NYISO and the Connecting 
Transmission Owner.  Certain aspects of the Facilities Study process thus may be best addressed 
through a coordinated FPA section 205 filing with the NYISO, rather than through unilateral action 
by the NYTOs.  Accordingly, without waiving their section 205 rights, the NYTOs intend to work 
with the NYISO and stakeholders toward a coordinated FPA section 205 filing addressing the load 
interconnection and service processes because the NYTOs believe this will produce the most 
efficient results on a necessarily coordinated process.  The NYTOs have a strong track record of 
working with the NYISO on shared responsibility for interconnection and transmission planning, 
as evidenced by the recent Order Nos. 2023 and 1920 compliance filings.  The NYTOs anticipate

23 
working through the coordinated process with the NYISO to develop improved large load 
interconnection processes as well.  
The NYTOs will work with the NYISO and stakeholders to address the following key 
elements with respect to the interconnection study provisions in the anticipated FPA section 205 
filing: 
 
First, the NYTOs will work with the NYISO and stakeholders to develop Tariff provisions 
governing the Facilities Study process for large load interconnections.  Consistent with the 
coordinated approach described above, the NYTOs anticipate working with the NYISO and 
stakeholders toward Tariff provisions addressing, among other things, (1) the steps and process 
for conducting the Facilities Study, (2) the additional information the Eligible Customer or large 
load customer, as appropriate, must provide to the Connecting Transmission Owner in connection 
with the Facilities Study, and (3) the outputs of the Facilities Study, including the scope and form 
of the cost estimates and study report delivered to the Eligible Customer.  Because the NYTOs 
bear primary responsibility for the Facilities Study due in part to the financial and operational risk 
associated with facilities needed to interconnect large load customers, the NYTOs are well-
positioned to help develop these provisions. 
Second, the NYTOs will work with the NYISO and stakeholders on the scope of the Load 
SIS, including modifications to account for the unique characteristics of certain large loads.  
Specifically, for large loads with unique load characteristics – such as those with arcuate or non-
linear load profiles – the standard Load SIS scope might not be enough to thoroughly assess 
interconnection impacts.  Additional specialized screenings may be required at an early stage of 
the study process – for example, unit interaction factor analysis – to determine whether a large 
load can interconnect to the transmission system without requiring Network Upgrades.  The FPA

24 
section 205 filing will address whether such SIS scope modifications should be: (a) identified and 
applied at the Load SIS stage; or (b) addressed in the second phase of the study process, during 
which alternative upgrade evaluations are conducted.  The NYTOs intend to develop this proposal 
further during the abeyance period in consultation with the NYISO and the other parties. 
Third, the NYTOs intend to address an appropriate timeline for the Facilities Study process, 
including provisions addressing the timeline within which the Connecting Transmission Owner 
would complete the Facilities Study and deliver the study report and cost estimates to the Eligible 
Customer, as well as milestones and readiness requirements applicable to the Eligible Customer 
or large load customer, as applicable, during the Facilities Study process.  The NYTOs intend to 
develop the specific timeline provisions in consultation with the NYISO and stakeholders during 
the abeyance period. 
Fourth, the NYTOs intend to address whether and how the Facilities Study process should 
require evaluation of alternative transmission technologies as a potential substitute for traditional 
Network Upgrades identified to accommodate a large load interconnection.  Because the 
Connecting Transmission Owner develops the cost estimates and study report delivered to the 
Eligible Customer as part of the Facilities Study, the NYTOs are well-positioned to propose Tariff 
provisions requiring such an evaluation and, where traditional Network Upgrades are proposed 
instead, a clear explanation in the study report of why alternative transmission technologies were 
not selected.53 
As with the generator interconnection process, these Facilities Study provisions require 
significant collaboration, handoffs, and coordination among the NYTOs and NYISO.  While the 
substance of a Connecting Transmission Owner’s Facilities Study is primarily for the Connecting 
 
53  
Id. PP 67-68.

25 
Transmission Owner to determine, the NYTOs recognize that, as a practical matter, they will 
depend on certain NYISO inputs before the NYTOs can proceed with particular aspects of the 
Facilities Study.  Such inputs include the development of base cases, identification of bulk system 
violations, and the results of the alternate evaluation process described.  Close coordination on the 
timing of those inputs is essential, and the NYTOs accordingly intend to work closely with the 
NYISO to establish coordinated timelines and information-sharing protocols that account for this 
interdependency.   
2. 
Pro Forma Interconnection Agreement  
The Commission observed that the large load interconnection agreement is not included in 
the NYISO Tariff and is not subject to sufficiently clear or consistent pro forma provisions.54   
As the Commission has recognized,55 the absence of pro forma provisions in the 
interconnection agreement between the Transmission Owner and the Eligible Customer 
undermines the Transmission Owner’s ability to enforce the operational and cost-recovery 
requirements that arise from the study process.  The Transmission Owner – not NYISO – is the 
counterparty to the load interconnection agreement, and it is the Transmission Owner and its 
customers that bear the direct financial exposure to cost-shifting risk if the terms of that agreement 
are not standardized and clearly specified. 
As noted, the NYPSC commenced a proceeding to review large load interconnection and 
related service requirements and cost allocation.  Ideally, the NYPSC-developed requirements will 
be acceptable to the Commission for implementation without having to address any conflicts and 
jurisdictional or preemption issues.  Subject to consultation with NYISO and DPS, the NYTOs 
 
54  
Id. PP 29, 90.  
55  
Id. P 90.

26 
will develop pro forma terms and conditions that mirror terms approved by the NYPSC and are 
otherwise consistent across the state and federal levels. 
The NYTOs anticipate that the FPA section 205 filing will propose pro forma agreement 
and/or Tariff provisions to create a legally enforceable framework that addresses the operational 
rights and obligations of all relevant parties with respect to the large load.  Regardless of the 
ultimate form of the agreement(s) or Tariff provisions adopted, the NYTOs will work with the 
NYISO on an FPA section 205 filing to address, inter alia,  the following rights and obligations: 
(a) the NYISO’s and Connecting Transmission Owner’s rights to curtail, ramp down, and interrupt 
the large load; (b) the same rights of any Affected Transmission Owner, where applicable; and (c) 
a binding commitment of the large load to comply with all applicable operational requirements.  
The ultimate agreement should be designed to ensure that all parties with a need to (i.e., the 
NYISO, the Connecting Transmission Owner, and/or the Affected Transmission Owner) can 
enforce these rights and large load customer obligations. 
The NYTOs also intend to address the structure of the interconnection agreement or 
agreements that will govern the relationship among the NYISO, the Connecting Transmission 
Owner, and the large load.   The precise form of the agreement, agreements, or other Tariff changes 
has not yet been determined and will be the subject of further consultation between the NYTOs 
and NYISO during the abeyance period.  The NYTOs commit to working with the NYISO and 
stakeholders on a legally enforceable framework addressing the rights and obligations of the 
parties with respect to these important matters.

27 
C. 
Operating Terms Applicable to Non-Firm Transmission Withdrawal Service 
and Paired or Behind-the-Meter Generation Supplies 
The NYISO is responsible for the reliability of the New York bulk power system.56  The 
NYTOs are responsible for the reliable operation of their systems, including local (non-bulk) 
transmission and distribution systems.57  The NYTOs also have certain obligations under New 
York State law concerning the reliable operation of their systems.  With potentially large increases 
in the amount of new large loads on the system, and new non-firm or contract demand services, 
new operating requirements will be needed, as the Commission recognizes.58  The NYTOs will 
coordinate with the NYISO to develop operating requirements for loads that have chosen Non-
Firm Transmission Withdrawal Service where the service level is less than the maximum potential 
withdrawal of the load and for supply paired with load, or that is behind-the-meter generation and 
requests Energy Resource Interconnection Service (“ERIS”) and/or Capacity Resource 
Interconnection Service (“CRIS”) at a level below the maximum potential injection.  Associated 
large load customers and suppliers will be required to satisfy operating requirements allowing for 
dispatch, ramping, curtailment, interruption, and/or disconnection on an automated, NYISO-
controlled or Connecting Transmission Owner/Affected Transmission Owner-controlled, and 
remote basis, depending on the circumstances.59  
The NYTOs will work with the NYISO to develop a legally enforceable framework among 
the NYISO, NYTO, large load, and associated supplier – likely in the form of one or more pro 
forma agreements and/or Tariff provisions – to provide for operations requirements.  In some 
cases, the successful installation and testing of system protection schemes will be necessary at 
 
56  
See, e.g., ISO Agreement, § 6.02; NYISO-TO Agreement § 3.01.   
57  
See, e.g., NYISO-TO Agreement § 2.03.  
58  
Show Cause Order at P 109. 
59  
See id. P 113.

28 
energization and as a condition of continued operation.  System protection and control schemes, 
where they can be deployed consistent with applicable reliability requirements, are tailored to the 
specific characteristics of the load, supply, and the bulk power system and local transmission and 
distribution system needs to maintain reliability in the areas of the system affected by the 
interconnection and service requirements.  Each system protection and operations scheme will 
need to satisfy applicable reliability requirements as defined in the NYISO procedures. 
IV. 
REQUEST FOR EXPEDITED COMMISSION ACTION AND SHORTENED 
COMMENT PERIOD 
The NYTOs respectfully request that the Commission act on this request on or before 
August 13, 2026, to provide the NYTOs with certainty regarding the need to file a response to the 
Show Cause Order and to allow the NYTOs to focus their efforts on coordinating with the NYISO 
and stakeholders on an FPA section 205 filing.  Moreover, consistent with Rule 213(d) of the 
Commission’s Rules of Practice and Procedure,60 the NYTOs respectfully request that the 
Commission establish a 5-day comment period for any party wishing to respond to this request.  
V. 
COMMUNICATIONS 
All communications and correspondence regarding this filing should be forwarded to the 
following individuals, whose names should be placed on the Commission’s service list:61 
 
60  
18 C.F.R. § 385.213(d)(1)(i) (“If a motion requests an extension of time or a shortened time period for action, 
then answers to the motion to extend or shorten the time period shall be made within 5 days after the motion 
is filed, unless otherwise ordered.”). 
61  
The NYTOs respectfully request waiver of 18 C.F.R. § 385.203(b)(3) to allow more than two individuals to 
be designated for service on the official service list in this proceeding.

29 
William R. Derasmo 
C. Dixon Wallace III 
Antonia M. Douglas 
TROUTMAN PEPPER LOCKE LLP 
401 9th Street NW, Suite 1000 
Washington, DC 20004 
(202) 274-2886 
william.derasmo@troutman.com 
dixon.wallace@troutman.com 
antonia.douglas@troutman.com 
 
Marina Chu 
Regulatory Attorney – Regulatory Affairs 
Central Hudson Gas & Electric Corporation 
284 South Avenue 
Poughkeepsie, NY 12601 
mchu@cenhud.com 
 
Phillip D. Demanchick Jr. 
Senior Counsel 
New York State Electric & Gas Corporation 
Rochester Gas and Electric Corporation 
180 South Clinton Avenue 
Rochester, NY 14604 
phillip.demanchick@avangrid.com
Christopher J. Novak 
Senior Counsel 
National Grid USA 
170 Data Drive 
Waltham, MA 02451 
chris.novak@nationalgrid.com 
 
 
Lauren A. Jones 
Associate General Counsel 
Joshua A. Kirstein 
Senior Attorney 
Consolidated Edison Co. of New York, Inc. 
Orange and Rockland Utilities, Inc. 
4 Irving Place 
New York, NY 10003 
jonesl@coned.com 
kirsteinj@coned.com 
 
VI. 
CONCLUSION 
WHEREFORE, for the foregoing reasons, the NYTOs respectfully request that the 
Commission grant a full 90-day abeyance for the aspects of the Show Cause Order referenced 
above, including the deadline to respond to the Show Cause Order, commencing as of the deadline 
to respond to the Show Cause Order, to allow the NYTOs the time necessary to develop in 
coordination with the NYISO, NYPSC, and stakeholders, and file a comprehensive, regionally-
tailored FPA section 205 filing that addresses the concerns identified in the Show Cause Order.

30 
Respectfully submitted, 
 
 
 
 
 
 
 
/s/ William R. Derasmo  
William R. Derasmo 
C. Dixon Wallace III 
Antonia M. Douglas 
TROUTMAN PEPPER LOCKE LLP 
 
Counsel to the New York Transmission Owners 
 
 
 
 
 
       
/s/ Marina Chu 
Marina Chu 
Central Hudson Gas & Electric 
Corporation 
 
/s/ Phillip D. Demanchick Jr. 
Phillip D. Demanchick Jr. 
New York State Electric & Gas 
Corporation 
Rochester Gas and Electric Corporation
 
/s/ Christopher J. Novak 
Christopher J. Novak 
National Grid USA 
 
/s/ Joshua A. Kirstein 
Lauren A. Jones 
Joshua A. Kirstein 
Consolidated Edison Co. of New York, Inc. 
Orange and Rockland Utilities, Inc. 
 
Dated: August 3, 2026

CERTIFICATE OF SERVICE 
 
I hereby certify that on this 3rd day of August, 2026, I have served a copy of the foregoing 
document on the official service list compiled by the Office of the Secretary for the captioned 
proceeding.  
 
 
 
 
 
 
 
/s/ Daryl A. Bascus 
 
 
 
 
 
 
 
Daryl A. Bascus 
 
 
 
 
 
 
 
FERC Energy Specialist 
 
 
 
 
 
 
 
TROUTMAN PEPPER LOCKE LLP 
 
 
 
 
 
 
 
401 9th Street NW, Suite 1000 
 
 
 
 
 
 
 
Washington, DC 20004 
 
 
 
 
 
 
 
(202) 274-1949 
 
 
 
 
 
 
 
daryl.bascus@troutman.com